What Are Animal By-Products and How Are They Categorized?
Animal By-Products (ABPs) are materials of animal origin that are not intended for humans to eat. They include, for example: parts of slaughtered animals not used as food (skins, bones, blood, fat, offal, etc.), entire carcasses of animals that died on farms, pet animal remains, by-products from animals like manure, eggshells, feathers, wool, and former foodstuffs of animal origin that are no longer fit for sale. Because ABPs can potentially spread diseases if not handled properly, EU law classifies them into three categories based on risk level:
- Category 1 (Cat 1) – High-risk materials. This category includes the highest-risk ABPs, such as: all parts of animals suspected or confirmed to have TSEs (e.g. BSE in cattle), animals killed in the context of TSE eradication, pet animals, zoo or circus animals carcasses, animals used in experiments, wild animals suspected of communicable diseases, and any specified risk material (SRM) (parts most likely to carry TSE agents, like bovine spinal cord). It also includes international transport catering waste (food waste from airplanes or ships) and any mixture containing Category 1 material (if Cat1 is mixed with Cat2 or Cat3, the whole lot becomes Cat1). Category 1 materials pose the greatest risk and must be strictly disposed of (usually by incineration), never entering feed or food chains.
- Category 2 (Cat 2) – Moderate-risk materials. This includes high-risk materials that are not Cat1. Examples are: animals or parts rejected from slaughterhouses due to infectious disease, carcasses of animals that died on farm (fallen stock), animals killed for disease control, products containing excess residues of veterinary drugs, manure and digestive tract contents, and any mixture of Category 2 and 3 material (which is treated as Cat2). Category 2 material is also unsuitable for feed use (except for specific cases like certain processed manure in fertilizer) and is typically used for limited purposes like biogas production, organic fertilizer (after processing), or must be destroyed. In short, if a material is not Cat1 but is unfit for the feed/food chain, it falls in Cat2.
- Category 3 (Cat 3) – Low-risk materials. Category 3 comprises ABPs that are low risk to health. These are often materials that originally come from healthy animals slaughtered for food. For example: parts of slaughtered animals that were passed fit for human consumption but are not used for food (due to commercial reasons or because they’re not commonly eaten parts), products of animal origin originally meant for human consumption but withdrawn for reasons not related to safety (e.g. product surplus or packaging defects), domestic catering waste (household kitchen scraps), shells from shellfish, eggs, egg by-products and eggshells, fish or other sea animals, and by-products like hides, skins, hooves, feathers, wool, horns and hair from healthy slaughtered animals Only Category 3 material can be used in feed for farmed animals, and even then under strict conditions. Cat 3 is commonly used for making pet food, animal feeds, organic fertilizers, or biofuels, since it’s considered safe if properly processed. However, it still must be labeled “Not for human consumption” to prevent any accidental entry into the human food chain.
Main Legal Framework: Regulations (EC) 1069/2009 and (EU) 142/2011
The handling and trade of ABPs in the EU is governed by a comprehensive legal framework. The cornerstone is Regulation (EC) No. 1069/2009, which lays down health rules for animal by-products and derived products not intended for human consumption, and its implementing Commission Regulation (EU) No. 142/2011. These regulations set out the requirements for safe sourcing, processing, transport, use, and disposal of ABPs, with the overarching goal of protecting public and animal health. The main principles of the law are safe sourcing, safe treatment, and safe end use, achieved through strict traceability and risk-based measures at every step.
In practice, this means there are clear rules on how each category of ABP must be processed or disposed of, technical standards for facilities, official approvals, and controls. For instance, Category 1 material can only be disposed by approved incineration or similar methods and cannot be reused, whereas Category 3 material can be processed into feed or fertilizer under specific conditionsfood.ec.europa.eu. The legislation also introduces the concept of an “end point” in the manufacturing chain for certain products. Once an ABP-derived product is processed to a point that it’s deemed safe (e.g. finished pet food, certain organic fertilizers), it may no longer be subject to ABP rules and can be traded freely as a normal productfood.ec.europa.eu. (For example, fully tanned hides or commercially canned pet food reach an end point where ABP regulations no longer apply.)
Registration and Approval of Establishments: A key aspect of the framework is that any business handling ABPs must be known to authorities. Operators must be registered or approved by the competent authority in their country for the specific activities and ABP categories they handleeur-lex.europa.eu. Only facilities that meet the strict processing/hygiene standards receive approval (and an approval number). The EU maintains lists of all approved ABP establishments per Member Statefood.ec.europa.eu, and both the sender and receiver of ABPs in intra-EU trade must be on these lists. In other words, you cannot ship ABPs to an unapproved facility. Always ensure that your facility and your trading partner’s facility are correctly approved/registered for the category of ABP in question.
TRACES NT System and DOCOM Documents for Intra-EU Movements
To facilitate safe trade and official control, the EU uses an electronic system called TRACES NT (“Trade Control and Expert System, New Technology”). TRACES NT is a centralized online platform for sanitary and phytosanitary certifications and tracking – it’s used for imports into the EU as well as for intra-EU movements of animals and certain animal products, including ABPs. When you are moving ABPs from one Member State to another, you do not simply send them with a paper document. Instead, you must use TRACES NT to create a digital commercial document for the shipment, known as a DOCOM (short for “document commercial”).
A DOCOM in TRACES NT is essentially the electronic form of the commercial document required by law to accompany ABP transports. It contains key information about the consignment, such as:
- A detailed description of the material, the category, and quantity (e.g. “Category 3 – 2,000 kg of bovine hides”),
- The date of dispatch,
- The name, address, and contact details of the dispatch establishment and the destination establishment, along with their approval or registration numbers,
- The means of transport (e.g. container ID, vehicle registration) and
- The name and signature of the responsible person for the consignment.
This electronic document is then accessible to the competent authorities in both the exporting and importing country via TRACES. Once the operator (exporter) fills Part I and II of the DOCOM on TRACES, the system notifies the official veterinarian in the country of origin to validate it, and also alerts the destination country’s authorities that an ABP shipment is on the way. This provides real-time traceability and oversight. The TRACES platform is available in all EU languages and provides a harmonized, paperless workflow across the EU.
Obligations of Exporters and Importers of ABPs
- Use Approved Establishments: Only source from and ship to facilities that are officially approved or registered for handling animal by-products. Both the dispatch and destination locations must appear on the EU’s list of approved ABP establishments. Before arranging a shipment, verify the approval status and the approval number of the supplier/recipient. Shipping ABPs to an unapproved facility (or buying from one) is prohibited and can result in the shipment being stopped by authorities.
- Correct Categorization and Segregation: You must accurately identify the category of the ABP you are dealing with (Cat 1, 2, or 3) and handle it accordingly. Do not mix different category materials in the same container or shipment. If materials of different categories are mixed, the entire mixture is treated as the highest risk category present. For example, if a bit of Cat 2 material gets mixed into Cat 3 material, the whole batch must be treated as Cat 2 (and will face Cat 2 restrictions). Maintain strict separation of categories in storage and transport to avoid cross-contamination. Category must also be clearly indicated on documents and labels.
- Labeling Requirements: All ABPs must be clearly labeled during transport and storage to prevent misuse. Containers, packages, and vehicles carrying ABPs should have a label indicating the category and a warning or destination statement. EU regulations specify standard wording for labels: Category 1 material should be marked “For disposal only” (indicating it must be destroyed), Category 2 “Not for animal consumption” (not to be fed to animals), and Category 3 “Not for human consumption”. Ensure these labels are securely attached and visible. Proper labeling is crucial so that everyone (from transporters to customs or plant workers) knows the material’s status at a glance.
- Documentation and Notification: Every shipment of ABPs must be accompanied by the proper documentation. In most cases this is the commercial document (DOCOM) generated through TRACES NT, or in some cases an official health certificate. The document should travel with the consignment (at least a printed copy or a digital PDF that authorities can access). It must contain all required details (description, category, quantity, origin, destination, approvals, etc.) and be signed by the responsible person. You are responsible for completing the TRACES NT notification for the shipment ahead of time, and for ensuring the information is correct. Failure to have the right paperwork can lead to border delays or refusal of entry for the goods.
- Record-Keeping and Traceability: Operators sending, transporting, or receiving ABPs are required to keep records of all consignments and the related documents. You should maintain a log (electronically or on paper) of every ABP shipment that leaves or arrives at your facility. This record should include the date, description of material (with category), quantity, and the details of the sender/receiver for each consignment. EU law mandates that these records and copies of commercial documents be retained for a minimum period (typically at least 2 years) for auditing purposes. Having a robust record-keeping system not only keeps you compliant with traceability rules,but also helps quickly address any issues (e.g. in case of a product recall or disease outbreak, you can identify where material came from and went to).
- Hygiene and Transport Conditions: ABPs sho uld be transported in a manner that does not pose a health risk. This means using leak-proof, covered containers/vehicles, and maintaining proper temperature or other conditions if required (for example, certain fresh ABPs might need refrigeration). After transporting high-risk materials, the vehicle and containers must be cleaned and disinfected thoroughly to avoid contaminating the next load. If you carry different categories of ABP or alternate between ABP and food/feed in the same truck, implement strict cleaning protocols. The law provides for measures to ensure safe transport – including separation of categories, proper labeling, and container integrity during transport to prevent any leakage or spread of pathogens. Drivers and personnel handling these products should be aware of and follow biosecurity measures (like wearing protective clothing and cleaning equipment).